Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
Employee stock-shortage penalties do not constitute consideration for services, preventing GST collection under Schedule II in employment relationship...
Transfer pricing adjustment - arm's length price of broking commission - selection of most appropriate method - considering brokerage rate of all non-associates for comparability - TPO rejected TNMM, applied CUP method - directed to consider both overseas and domestic clients while applying CUP method. No adjustment of marketing cost while applying CUP method, not granting adjustment of research cost and volume - directed to allow 40% adjustment on marketing and research cost. Computing upward adjustment by considering addition instead of rectified amount - issue restored to AO for giving effect as per TPO's rectification order. Disallowance of net loss incurred on error trading transactions - directed to allow as incidental to assessee's broking business. Disallowance u/s 14A - issue remanded to AO to examine disallowance and assessee to substantiate claim.
Transfer pricing adjustment - arm's length price of broking commission - selection of most appropriate method - considering brokerage rate of all non-associates for comparability - TPO rejected TNMM, applied CUP method - directed to consider both overseas and domestic clients while applying CUP method. No adjustment of marketing cost while applying CUP method, not granting adjustment of research cost and volume - directed to allow 40% adjustment on marketing and research cost. Computing upward adjustment by considering addition instead of rectified amount - issue restored to AO for giving effect as per TPO's rectification order. Disallowance of net loss incurred on error trading transactions - directed to allow as incidental to assessee's broking business. Disallowance u/s 14A - issue remanded to AO to examine disallowance and assessee to substantiate claim.
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